This responds to your submission of March 22, 1993, concerning the use of by-product ethylene glycol in the manufacture of polyethylene terephthalate (PETE) resin intended for food-contact use. You stated that the ethylene glycol is reclaimed by the XXX XXXX XXXX XXXX as a by-product from their manufacturing process for virgin polyester polymers that are currently regulated by FDA for food-contact use, under § 177.1630 of Title 21 Code of Federal Regulations (21 CFR 177.1630). You further stated that the by-product ethylene glycol is purified by XXXXX using a XXXX XX XXXX procedure.

Based on our review of the data you provided, we believe that ethylene glycol, reclaimed as a by-product from the manufacturing process for polyester polymers complying with 21 CFR 177.1630 and re-purified by XXXX XXXX XXXXX XXXXX XXXXX process, is of a suitable purity for reuse in the production of PET resins intended for food-contact use, in accordance with 21 CFR 174.5.

We trust this letter responds fully to your request on this matter. If you have any further questions, please do not hesitate to contact our Indirect Additives Branch at 202-254-9511.